IRS Update

Matthew Wall Tax, Transfer Price

The IRS launch campaign to audit U.S. distributors that buy goods from related parties in other countries.

CRA Update

Matthew Wall CRA Updates, Transfer Price

MDW explained the Department of Finance Canada issued draft amendments for the Income Tax Act to include Country-by-Country Reporting as part of the OECD BEPS measures.

Expert Witness

Matthew Wall Expert Witness

Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.

CRA Update

Matthew Wall CRA Updates

MDW explained the Federal Budget will give the CRA $444 million over five years to crack down on tax evasion and tax avoidance with an expected return of $2.5 billion of additional revenue.

CRA Update

Matthew Wall CRA Updates

MDW explained the CRA’s latest Transfer Pricing Memo (TPM-17) says government assistance should not be used to lower the fee for related party services using the cost plus a mark-up.

Tax Hyperion Vol 13, Issue 1

Matthew Wall Tax

Carswell’s Tax Hyperion published “Warning: Tax Authorities are Auditing Inter-Company Loans and Other Financial Transactions” by Matthew Wall.

Tax Hyperion Vol 12, Issue 12

Matthew Wall Tax

Carswell’s Tax Hyperion published “Why Transfer Pricing Disputes are on the Rise for Companies of All Sizes” by Matthew Wall.

OECD – Intangibles

Matthew Wall OECD

MDW explained the final revisions to the OECD Guidelines for Chapter VI on Intangibles states the legal owner of intangibles does not have the right to all of the intangible profits.

OECD – Cash Boxes

Matthew Wall OECD

MDW explained taxpayers with a “cash box” in a low or no-tax jurisdiction must review the 2015 OECD Guidelines and might need to revise their corporate structure, transactions between related parties, or both, to mitigate the risk of a dispute.